The adoption in the Act and the administrative practices of Revenue Canada of the OECD's contemporary conception of the arm's length
principle in itself is not problematic.
All of the principals of Local Fone, SelectComm and Ribbon are arm's length
parties to Ribbon.
According to Notice 2003-47, the IRS will insist on immediate income inclusion of the value of the deferred payment for the options, regardless of whether the sale is at arm's length
The same criteria would be applied in determining whether the price is arm's length
, and the Inland Revenue will have the same opportunity for review and adjustment.
TORONTO -- Goldeye (TSX VENTURE:GGY) is pleased to announce that it completed an arm's length
private placement on December 30, 2005 for gross proceeds of $124,000, subject to acceptance by the TSX Venture Exchange.
Taxpayers asserted that the transaction was at arm's length
, because the FCE paid FMV for the options (which was usually determined under the Block-Scholes method).
65-17 because the arm's length
goal of section 482 is the same in both cases.
Howard Phee, announces that it has reached an agreement, subject to regulatory approval, with certain of its arm's length
and one non-arm's length
supplier of services and creditors to settle debt totaling $105,150 by the issuance of 525,750 common shares of stock of the Company at a deemed value of $0.
However, in this case, the agreement was negotiated at arm's length
and serves as a real and discernable business for the charity.
any two corporations where either one controls the other by reference to the ownership of more than 50 percent of the shares entitled to vote, or both are so controlled by the same party), they are deemed, under section 251(l), not to deal at arm's length
TORONTO -- Pele Mountain Resources (TSX VENTURE:GEM) ("Pele" or the "Company") is pleased to announce that it has completed, subject to regulatory approval, a private placement to eleven (11) arm's length
subscribers of a total of 1,800,000 flow-through units in the capital of Pele (each a "Flow-Through Unit") at a purchase price of $0.
Further, the expenses were not ordinary and necessary and the transactions were not at arm's length